Madras High Court
WP/41115/2026 of Sathya Hitech Solutions LLP Vs State Tax Officer on 13 October 2026
WP No. 41115 of 2026
IN THE HIGH COURT OF JUDICATURE AT MADRAS
DATED: 14-10-2026
CORAM
THE HON'BLE MR JUSTICE KRISHNAN RAMASAMY
WP No. 41115 of 2026
CNR:{HCMA012323072026}
AND
WP NO. 41122 OF 2026,WP NO. 41128 OF 2026,WP NO. 41131 OF
2026,WMP NO. 46145 OF 2026,WMP NO. 46149 OF 2026,WMP NO.
46154 OF 2026,WMP NO. 46165 OF 2026
Sathya Hitech Solutions LLP,
Represented by its Designated Partner,
Mr.Gurusankar Vivek Subramaniam,
No.222, Chinnammal Nagar,
Edayarpalayam-Vadavalli Road,
Coimbatore 641 041.
..Petitioner(s)
Vs
State Tax Officer,
Roving Squad - 4,
Coimbatore.
..Respondent(s)
WP No. 41122 of 2026
CNR:{HCMA012309472026}
Sathya Hitech Solutions LLP,
Represented by its Designated Partner,
Mr.Gurusankar Vivek Subramaniam,
No.222, Chinnammal Nagar,
Edayarpalayam-Vadavalli Road,
Coimbatore 641 041.
..Petitioner(s)
Vs
State Tax Officer,
Roving Squad - 4,
Coimbatore
..Respondent(s)
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WP No. 41115 of 2026
WP No. 41128 of 2026
CNR:{HCMA012309502026}
Sathya Hitech Solutions LLP,
Represented by its Designated Partner,
Mr.Gurusankar Vivek Subramaniam,
No.222, Chinnammal Nagar,
Edayarpalayam-Vadavalli Road,
Coimbatore 641 041.
..Petitioner(s)
Vs
State Tax Officer,
..Respondent(s)
WP No. 41131 of 2026
CNR:{HCMA012323062026}
Sathya Hitech Solutions LLP,
Represented by its Designated Partner,
Mr.Gurusankar Vivek Subramaniam,
No.222, Chinnammal Nagar,
Edayarpalayam-Vadavalli Road,
Coimbatore 641 041.
..Petitioner(s)
Vs
State Tax Officer,
Roving Squad - 4,
Coimbatore.
..Respondent(s)
PRAYER: The Writ Petition is filed under Article 226 of the Constitution of India seeking the issuance of a Writ of Certiorari calling for the records relating to the Form GST DRC-07 Order in Reference No. ZD330626285429X
in GSTIN. 33ACJFS1582J1ZW / 2023-24 dated 30-6-2026 passed by the respondent and to quash the same as made without considering the reply with
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WP No. 41115 of 2026
documents and Additional submissions filed on 30-6-2026 contrary to Section 75(6 ) Section 75(7) of the GST Act and without authority and thus render justice.
WP No. 41122 of 2026
PRAYER: The Writ Petition is filed under Article 226 of the Constitution of India seeking the issuance of a Writ of Certiorari calling for the records relating to the Form GST DRC-07 Order in Reference No. ZD330626282800C
in GSTIN 33ACJFS1582J1ZW / 2022-23 dated 30-6-2026 passed by the respondent and to quash the same as made without considering the reply with documents And Additional submissions filed on 30-6-2026 contrary to Section 75(6) Section 75(7) of the GST Act and without authority and thus render justice.
WP No. 41128 of 2026
PRAYER: The Writ Petition is filed under Article 226 of the Constitution of India seeking the issuance of a Writ of Certiorari calling for the records relating to the Form GST DRC-07 Order in Reference No.ZD3306262731958
In GSTIN 33ACJFS1582J1ZW / 2021-22 dated 29-6-2026 passed by the respondent and to quash the same as made without considering the reply with documents And submissions filed on 29-6-2026 contrary to Section 75(6)
Section 75(7) of the GST Act and without authority and thus render justice.
WP No. 41131 of 2026
PRAYER: The Writ Petition is filed under Article 226 of the Constitution of India seeking the issuance of a Writ of Certiorari calling for the records relating to the Form GST DRC-07 Order in Reference No.ZD3306262876431
in GSTIN. 33ACJFS1582J1ZW / 2024-25 dated 30-6-2026 passed by the respondent and to quash the same as made without considering the reply with documents And Additional submissions filed on 29-6-2026 contrary to Section 75(6) Section 75(7) of the GST Act and without authority and thus render justice.
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WP No. 41115 of 2026
For Petitioner(s) in all
petitions:
Mr.K.JAYACHANDRAN
For Respondent(s) in all
petitions:
Mr.R.Sethu Prabakaran, Government Advocate (Taxes)
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Common Order
The present Writ Petitions have been filed challenging the assessment order passed in Form GST DRC-07.
2. The learned counsel for the petitioner submits that the respondent initiated proceedings under Section 74 of the CGST Act for the assessment years 2021-22, 2022-23, 2023-24, and 2024-25, alleging certain discrepancies. Although the Show Cause Notice (SCN) / DRC-01 dated 29.04.2026 was issued, it failed to mention the specific authority before whom the petitioner was required to file a reply. However, by a letter dated 08.06.2026, the petitioner requested an extension of time, and subsequently filed a detailed reply on 29.06.2026. Despite this, the impugned order was passed on the very next day, i.e., 30.06.2026, without affording the petitioner an opportunity for a personal hearing as mandated under Section 75(4) of the CGST Act. The learned counsel contends that the proposal was issued without conducting any reconciliation of the petitioner’s books of accounts, purchase registers, and statutory records. Under such circumstances, the petitioner was completely
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WP No. 41115 of 2026
denied an effective opportunity to place its explanation and supporting documents before the respondent. It is further contended that the mandatory requirement of an effective personal hearing under Section 75(4) of the CGST Act has been bypassed, resulting in a gross violation of the principles of natural justice.
3. On the other hand, the learned Government Advocate (Taxes) appearing for the respondent submits that the respondent had duly uploaded the notices on the GST online portal and that the petitioner had also filed a detailed reply on 29.06.2026. He submits that the respondent passed the impugned order only after considering the said reply. However, he fairly admits that no effective opportunity for a personal hearing was provided to the petitioner prior to the passing of the impugned order. Therefore, he requests this Court to remit the matters back to the respondent for fresh consideration.
4. Heard the learned counsel for the petitioner and the learned Government Advocate (Taxes) for the respondent, and perused the materials available on record.
5. Considering the facts and circumstances of the case, this Court is of the view that the respondent’s act of passing the impugned assessment order on 30.06.2026, immediately on the day following the filing of the reply and
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WP No. 41115 of 2026
without providing an opportunity for a personal hearing, constitutes a clear and undeniable violation of the principles of natural justice.
6. In view of the foregoing facts and circumstances, this Court is inclined to set aside the impugned orders dated 30.06.2026.
7. Accordingly, this Court passes the following order:—
(i) The impugned orders are set aside and the matter is remanded to the respondent for fresh consideration. .
(ii) As the reply has already been filed, the respondent shall consider the same and issue a clear 14-day notice fixing the date of the personal hearing to the petitioner. Thereafter, the respondent shall pass appropriate orders on merits and in accordance with law, after hearing the petitioner, as expeditiously as possible.
8. With the above directions, these writ petitions are disposed of. No costs. Consequently, connected miscellaneous petitions are closed. 14-10-2026 Index: Yes/No Speaking/Non-speaking order Neutral Citation: Yes/No SK
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WP No. 41115 of 2026
To State Tax Officer, Roving Squad - 4, Coimbatore.
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WP No. 41115 of 2026
KRISHNAN RAMASAMY J. SK WP No. 41115 of 2026 AND WP NO. 41122 OF 2026,WP NO. 41128 OF 2026,WP NO. 41131 OF 2026,WMP NO. 46145 OF 2026,WMP NO. 46149 OF 2026,WMP NO. 46154 OF 2026,WMP NO. 46165 OF 2026 14-10-2026
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WP No. 41115 of 2026
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